METHYL BROMIDE CRITICAL USE RENOMINATION FOR POST-HARVEST -- DRY CURED
PORK PRODUCTS 

Nominating Party: The United States of America

FILE NAME  USA CUN13 POST HARVEST -- Dry, Cured Pork Products 

Brief descriptive Title of Nomination:

Methyl Bromide Critical Use Nomination for Post Harvest Use on Dry Cured
Pork Products (Submitted in 2011 for 2013 Use Season)

STRUCTURE, COMMODITY or OBJECT TREATED:

This sector is for the production of cured meat products, such as
country hams.  These are produced primarily in the southern U.S.  This
sector has no known viable alternative currently available.  

Quantity of methyl bromide requested in each year of nomination:

Table 1: Quantity of Methyl Bromide Requested in Each Year of Nomination

Year	Nomination Amount (kilograms)

2013	3,730



(Details on this page are requested under Decision Ex. I/4(7), for
posting on the Ozone Secretariat website under Decision Ex. I/4(8).) 

In assessing nominations submitted in this format, TEAP and MBTOC will
also refer to the original nomination on which the Party’s first-year
exemption was approved, as well as any supplementary information
provided by the Party in relation to that original nomination.  As this
earlier information is retained by MBTOC, a Party need not re-submit
that earlier information.   

NOMINATING PARTY CONTACT DETAILS:

Contact Person:	John Thompson	

Title:	Foreign Affairs Officer	

Address:	Office of Environmental Policy	

	U.S. Department of State	

	2201 C Street, N.W. Room 2658	

	Washington, D.C. 20520	

	U.S.A.	

Telephone:	(202) 647-1123	

Fax:	(202) 647-5947	

E-mail:	 HYPERLINK "mailto:ThompsonJH@state.gov" ThompsonJH@state.gov  

■  Yes	            ( No

					

Signature				Name					Date

Title:      			

CONTACT OR EXPERT(S) FOR FURTHER TECHNICAL DETAILS:

Contact/Expert Person:	Jack Housenger	

Title:	Division Director 	

Address:	Biological and Economic Analysis Division			

	Office of Pesticide Programs

	U.S. Environmental Protection Agency

	1200 Pennsylvania Avenue, N.W. Mailcode 7503P

	Washington, D.C. 20460

	U.S.A.	

Telephone:	(703) 308-8200		

Fax:	(703) 308-7042	

E-mail:	Housenger.jack@epa.gov

		

LIST OF DOCUMENTS SENT TO THE OZONE SECRETARIAT IN OFFICIAL NOMINATION
PACKAGE:

1.  PAPER DOCUMENTS:  

Title of paper documents and appendices	No. of pages	Date sent to Ozone
Secretariat

















2.  ELECTRONIC COPIES OF ALL PAPER DOCUMENTS:  

*Title of each electronic file (for naming convention see notes above)
No. of kilobytes 	Date sent to Ozone Secretariat

USA CUN13 Post Harvest Ham















* Identical to paper documents

METHYL BROMIDE CRITICAL USE RENOMINATION FOR POST-HARVEST -- DRY CURED
PORK PRODUCTS 

1.  SUMMARY OF NEED FOR METHYL BROMIDE AS A CRITICAL USE

Currently there are no viable alternatives to methyl bromide for the
dried meat industry:  heat would alter the product, and phosphine may
not control mites, a major pest.  Sulfuryl fluoride received federal
registration and has been tested for efficacy against the mites and
other pests of cured meat products.  Although mortality of the
red-legged ham beetle occurred at levels below maximum rates of sulfuryl
fluoride, the same cannot be said for the ham mites (Phillips, et al.,
2008).  Control of the ham mites took three times the legal limits of
sulfuryl fluoride (Phillips, et al., 2008).  At the time of this
nomination there are no known registered alternatives for use on hams in
the U.S. that provide the same level of pest control as methyl bromide.

This industry is cooperating with university researchers to find
technically and economically feasible alternatives to methyl bromide. 
In the meantime, this industry is using IPM techniques to manage their
pest populations.  All use sanitation to keep their curing facilities
clean.  Several companies have modified their buildings to make them
more gas-tight.  Some companies are eliminating grass, trees, and shrubs
from their buildings and replacing it with gravel, as suggested by
researchers in 2008.  Many use pheromone traps; however, these traps
only used for monitoring purposes at this time (Arthur and Phillips,
2003).  

This industry currently has no viable chemical alternative available. 
Although its IPM measures may have reduced the number of times
fumigation is needed in some facilities, it has not eliminated the need
for fumigation.  Therefore, methyl bromide remains critical to this
industry.  

Table 2.  Nomination Amount 

2.  SUMMARIZE WHY ALTERNATIVES ARE NOT FEASIBLE

This industry currently has no known viable chemical alternative
available.  Although its IPM measures may have reduced the number of
times fumigation is needed, it has not eliminated the need for
fumigation.  Therefore, methyl bromide remains critical to this
industry.  

3.  RESEARCH RESULTS SHOWING EFFICACY OF ALTERNATIVES

Researchers are currently investigating the control of arthropod pests
that infest dry cured pork products during the aging process.  In the
spring of 2007, a proposal was submitted to the USDA CSREES Integrated
Research, Education, and Extension Competitive Grants Program- Methyl
Bromide Transitions by several meat scientists and an entomologist. 
This proposal was funded from 2007 to 2010.  A no-cost extension was
granted for 2010-2011, and additional funding has been provided through
the Southern Regions Integrated Pest Management Center to continue
research efforts for 2010 and 2011.  In addition, a grant will be
submitted to the USDA in 2011 to seek funds to continue research with
respect to potential alternatives to methyl bromide for use in the dry
cured pork industry.  All of the research projects listed above and
below are being conducted in conjunction with the National Country Ham
Association, The American Association of Meat Processors, individual ham
producers, and fumigant companies.  

There were several objectives to the research project that was funded by
the USDA MBT program from 2007-2010.  The first objective was to
determine the effectiveness of chemical controls (sulfuryl fluoride,
phosphine, and methyl bromide) against all life stages of both mold
mites (Tyrophagus putrescentiae) and red legged ham beetles (Necrobia
rufipes).  The second objective was to determine the effectiveness of
carbon dioxide and ozone against all life stages of both mold mites and
red legged ham beetles.  The third objective was to test the effects of
sulfuryl fluoride, phosphine and methyl bromide on the quality and
safety of the dry cured hams.  The fourth objective was to conduct an
economic analysis of the alternatives demonstrated to be technically
viable alternatives for methyl bromide in this industry.  

The results of sulfuryl fluoride efficacy investigations on Tyrophagous
putrescentiae, ham mite, and Necrobia rufipes, red-legged ham beetle,
were presented at the 2008 MBAO Conference, in Orlando, FL.  The studies
included eggs and a mixture of adults and large nymphs of mites and the
eggs, large larvae, pupae and adults of beetles.  The experiments were
conducted for 48 hours at 23° C at various concentrations of sulfuryl
fluoride.  The investigators achieved 100% mortality of red-legged ham
beetle adults and pupae at about 4.0 g/m3, and 100% mortality of larvae
at 5.7 g/m3.  Eggs of red-legged ham beetles died at 24.0 g/m3 of
sulfuryl fluoride, well below the maximum label rate (Phillips et al.,
2008).  Mortality of ham mites required much higher concentrations of
sulfuryl fluoride.  A concentration of about 100.3 g/m3 was necessary to
obtain 100% mortality of adults and nymphs under the test conditions. 
However, this concentration obtained only a 95% mortality of mite eggs. 
This is about three times the legal label rate of sulfuryl fluoride
(Phillips et al., 2008) and thus indicates that sulfuryl fluoride is not
a viable alternative to methyl bromide for controlling ham mites.  In
addition, results also indicated that levels of residual fluoride and
sulfuryl fluoride in the hams were linearly related to fumigant
concentration and that use of high concentrations of sulfuryl fluoride
(72 g/m3 or greater) and multiple fumigations could potentially lead to
high concentrations of sulfuryl fluoride and fluoride in the ham (Sekhon
et al., 2010a). 

The results of carbon dioxide, phosphine, methyl bromide and ozone
efficacy investigations on Tyrophagous putrescentiae, ham mite, and
Necrobia rufipes, red-legged ham beetle, were presented at the 2009 MBAO
Conference, in San Diego, CA (Sekhon et al., 2009a, b; Phillips, 2009,
Sehkon et al., 2010b, 2010c).  The studies included eggs and a mixture
of adults and nymphs of mites and eggs, large larvae, pupae and adults
of beetles.  The experiments were conducted for variable times at 23° C
at various concentrations of carbon dioxide, phosphine, methyl bromide
and ozone.  The investigators achieved mortality of all life stages of
mites with a concentration of 60 % carbon dioxide with 144 hr of
exposure (Sekhon et al., 2009a; Phillips, 2009; Sehkon et al., 2010b). 
However, fumigation with carbon dioxide would likely not be applicable
since ham structures are not air-tight and 144 hr is too long of a time
to fumigate the hams.  In addition, a carbon dioxide concentration (> 80
%) with an exposure time of 144 hrs was necessary to cause 100 %
mortality for all life stages of red legged ham beetles (Sekhon, et al.
2009a; Phillips, 2009; Sehkon et al, 2010b).  In addition, there may be
higher numbers of ham mites that can hide in the crevices of the ham
that may be able to survive during CO2 fumigation.  

Investigators achieved 100 % mortality of all life stages of red legged
ham beetles and ham mites with 48 hours exposure of 400 and 1000 ppm of
phosphine, respectively (Sekhon, et al. 2009b; Phillips, 2009; Sekhon et
al., 2010c).  In addition, residual phosphine concentrations in dry
cured hams that were fumigated for 48 hrs at 1000 ppm were below 0.01
ppm, the legal residual limit in stored food products (Sekhon, et al.
2009b; Sekhon et al., 2010c), and consumer panelists could not detect
differences between control and phosphine fumigated samples at 1000 ppm
(Sekhon et al. 2009b; Sekhon et al., 2010c).  Therefore, phosphine can
now be considered a potential alternative to methyl bromide for
controlling arthropod pests of southern dry cured hams.  Further testing
with a greater number of mites has indicated that a greater
concentration of phosphine (>1000 ppm) is likely necessary to kill
substantial mite infestations.  In addition, commercial applications of
phosphine are planned for 2010-2011 to determine the efficacy of using
phosphine at the plant level. The effectiveness of phosphine will be
evaluated through the use of both bioassays (with ham present) and on
hanging hams in a simulated dry cured ham aging room.  

Other portions of this research include the economical analysis of using
phosphine in comparison to methyl bromide, if it is effective at
eradicating mites.  Commercial applicators and agricultural economists
are working with us on this portion of the research.  Additional items
that will be researched in the future (if funding is obtained) include
the effect of multiple fumigations on the sensory quality and residual
concentration of phosphine in ham, and the effectiveness of using
phosphine in dry cured ham facilities.  Many processors have indicated
that they would be willing to help evaluate the efficacy of phosphine
(at controlling ham mite infestations) in their plant as part of a
research project, which truly demonstrates the willingness of the
industry to do everything that they can to help determine if potential
alternatives to methyl bromide exist. In addition, we have commitments
from Universities and a commercial applicator to help implement
phosphine fumigation in dry cured ham facilities for this research to
take place.  

Ozone concentrations of greater than 150 ppm for 48 hrs were able to
achieve 100 % mortality of ham beetles and mites at the bench top level
(Sekhon et al., 2009b; Phillips, 2009; Sekhon et al., 2010b).  Consumers
also could not determine sensory differences between control hams and
those that were fumigated with ozone at 175 ppm for 48 hrs (Sekhon et
al., 2010b)).  However, ozone is not able to penetrate surfaces well and
therefore may not work well in real world applications since ham mites
could potentially penetrate into crevices in the meat and ham beetles
bore through the meat tissue. Research that was conducted by one dry
cured ham processor indicated that the use of ozone in a commercial
setting was not effective at eradicating ham mite infestations, which
was likely due to the inability of the ozone to penetrate the surface of
the ham and the ability of mites to find places to hide where the ozone
did not reach.  However, ozone may play a role in integrated pest
management to help minimize infestations and enhance sanitation since it
would sanitize areas in the plant as well as equipment that could
potentially harbor bugs and pathogens.

Further research has recently been conducted on the effects of low
pressure and low oxygen concentration on the mortality of Tyrophagous
putrescentiae (mold mites).  Exposure of mites to low oxygen with
pressure (25 mmHg; approx. 3.0% O2) at 23°C for 144 hrs or greater was
effective at eradicating more than 95 % of each mite life stage (Hasan
et al., 2010).  However, testing with a larger number of mites and under
commercial conditions would need to be conducted to determine if this
technology could be considered a potential alternative to methyl
bromide.  Its limitations include length of application, ability of
mites to hide within meat crevices, and difficulty in implementing at
the plant level.  

There is still no definitive alternative for methyl bromide for the dry
cured ham industry at this point in time.  Research is still ongoing
with phosphine, and controlled atmosphere, but more research and
commercial applications need to be conducted before any of these
treatments/fumigants can be considered alternatives to methyl bromide
for treatment of ham (mold) mites. 

4.  REGISTRATION UPDATE

No new chemicals have been registered nor de-registered since the last
nomination.  

5.  ECONOMIC INFEASIBILITY OF ALTERNATIVES 

An economic analysis was not conducted because this sector has no
technically feasible alternatives at this time.  

CITATIONS

Arthur, F. and T. W. Phillips.  2003.  Stored-product insect pest
management and control, In:  Food Plant Sanitation eds: Y. H. Hui, B. L.
Bruinsma, J. R. Gorham, W. Nip, P. S. Tong, and P. Ventresca.  Marcel
Dekker, Inc., New York, pp. 341-358.  

Hasan, M.M., Phillips, T.W., Aikins, J.M., Schilling, M.W. 2010.
Controlled atmosphere treatments to control arthropod pests of American
dry cured hams. Annual International Research Conference on Methyl
Bromide Alternatives and Emission Reduction, Orlando, FL, November
1st-5th

Phillips, T.W. Hasan, M.M., Aikens, M.J., Schilling, M.W. 2008. Efficacy
of sulfuryl fluoride to control ham mites and red-legged ham beetles. 
Annual International Research Conference on Methyl Bromide Alternatives
and Emission Reduction, Orlando, FL, November 11th-14th

Phillips, T.W. 2009. Personal Communication.

Sekhon, R.K., Schilling, M.W., Phillips, Hasan, M.M., Aikens, M.J,
Mikel, W.B. 2009. Chemical Composition of Dry Cured Hams Fumigated with
Carbon Dioxide. Annual International Research Conference on Methyl
Bromide Alternatives and Emission Reduction, San Diego, CA, November
10th-13th

Sekhon, R.K., Schilling, M.W., Phillips, Hasan, M.M., Aikens, M.J,
Mikel, W.B. 2009. Chemical composition of dry cured hams fumigated with
phosphine. Annual International Research Conference on Methyl Bromide
Alternatives and Emission Reduction, San Diego, CA, November 10th-13th

Sekhon, R.K., Schilling, M.W., Phillips, T.W., Hasan, M.M., Aikens, M.J.
Mikel, W.B. 2010a. Sulfuryl fluoride fumigation effects on the safety,
volatile composition, and sensory quality of dry cured ham. Meat
Science. 84(3):505-511.

Sekhon, R.K., Schilling, M.W., Phillips, T.W., Hasan, M.M., Aikens,
M.J., Nannapaneni, R., Mikel, W.B. 2010. Effects of carbon dioxide and
ozone treatments on the volatile composition and sensory quality of dry
cured ham. J. Food Science. 75(5):452-458.

Sekhon, R.K., Schilling, M.W., Phillips, T.W., Hasan, M.M., Aikens,
M.J., Corzo, A. Mikel, W.B. 2010. Effects of phosphine and methyl
bromide fumigation on the volatile flavor profile and sensory quality of
dry cured ham. Meat Science. 86(2):411-417. 

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